August 18, 2025
Section 232 trade Update: Steel and Aluminum Effective August 18, 2025
Section 232 Tariff Expansion – Steel Derivative Products (CSMS #65936570)
CBP has issued updated guidance regarding the implementation of Proclamation 10896, which expands Section 232 tariffs to include additional steel derivative products under the Harmonized Tariff Schedule of the United States (HTSUS), effective August 18, 2025.
Overview
Updated List of Steel HTS subject to Section 232
Section 232 Tariff Update – Additional Aluminum Derivative Tariff Inclusion Products (CSMS # 65936615)
In accordance with Presidential Proclamation 10895 (published February 10, 2025), the U.S. Department of Commerce has announced the inclusion of additional aluminum derivative products under Section 232 tariffs. These changes are reflected in Annex I of the Harmonized Tariff Schedule of the United States (HTSUS) and will take effect on August 18, 2025.
Overview:
New Tariff Classifications:
Entry Filing Instructions
Importers, brokers, and filers must ensure proper classification and duty reporting for goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, August 18, 2025. Refer to the updated aluminum HTS list for applicable eight-digit and ten-digit codes.
Smelt and Cast Reporting Requirements
ISO country codes must be reported for:
If origin is unknown, report “UN” – this will trigger the 200% duty rate for Russia-origin aluminum.
Recycled Aluminum Reporting
If aluminum is manufactured solely from recycled material, report “Y” for secondary smelt and use the country of origin as the smelt code. Supporting documentation may be required.
Additional Guidance
Updated List of Aluminum HTS subject to Section 232.
We will continue to monitor this situation and provide updates when available. Please contact us if you have any questions about this or any other trade matter.
CBP has issued updated guidance regarding the implementation of Proclamation 10896, which expands Section 232 tariffs to include additional steel derivative products under the Harmonized Tariff Schedule of the United States (HTSUS), effective August 18, 2025.
Overview
- Tariff Rate:
- 50% ad valorem on steel content for most countries
- 25% ad valorem for UK-origin goods
- 0% ad valorem for goods processed from U.S.-origin steel
- HTSUS Classifications Affected:
- 9903.81.90, 9903.81.91, 9903.81.97, 9903.81.98, 9903.81.92
- Applies to goods entered for consumption or withdrawn from warehouse on or after 12:01 a.m. EDT, August 18, 2025
- Foreign Trade Zones (FTZ):
- Goods with privileged foreign status admitted before August 18, 2025, are subject to the new tariffs if entered for consumption on or after the effective date.
- Reporting Requirements:
- Refer to CSMS #65236374 for steel content reporting instructions.
- Non-steel content may be subject to Reciprocal Tariffs under HTS 9903.01.25.
- Drawback Prohibition:
- No drawback is available for duties imposed under Proclamation 10896.
Updated List of Steel HTS subject to Section 232
Section 232 Tariff Update – Additional Aluminum Derivative Tariff Inclusion Products (CSMS # 65936615)
In accordance with Presidential Proclamation 10895 (published February 10, 2025), the U.S. Department of Commerce has announced the inclusion of additional aluminum derivative products under Section 232 tariffs. These changes are reflected in Annex I of the Harmonized Tariff Schedule of the United States (HTSUS) and will take effect on August 18, 2025.
Overview:
New Tariff Classifications:
- The following HTSUS Chapter 99 codes now apply to newly added aluminum derivative products:
- 9903.85.07 / 9903.85.08 – 50% ad valorem duty (all countries except UK)
- 9903.85.09 – 0% duty (U.S.-origin aluminum processed abroad)
- 9903.85.14 / 9903.85.15 – 25% ad valorem duty (UK only)
- 9903.85.68 / 9903.85.70 – 200% duty (Russia-origin aluminum or unknown smelt/cast origin)
Entry Filing Instructions
Importers, brokers, and filers must ensure proper classification and duty reporting for goods entered or withdrawn for consumption on or after 12:01 a.m. EDT, August 18, 2025. Refer to the updated aluminum HTS list for applicable eight-digit and ten-digit codes.
Smelt and Cast Reporting Requirements
ISO country codes must be reported for:
- Primary and/or secondary country of smelt
- Country of most recent cast
If origin is unknown, report “UN” – this will trigger the 200% duty rate for Russia-origin aluminum.
Recycled Aluminum Reporting
If aluminum is manufactured solely from recycled material, report “Y” for secondary smelt and use the country of origin as the smelt code. Supporting documentation may be required.
Additional Guidance
- Reciprocal Tariffs: Non-aluminum content may be subject to HTS 9903.01.25; aluminum content under Section 232 is exempt from HTS 9903.01.33.
- Drawback Prohibition: No drawback is available for Section 232 duties.
- Foreign Trade Zones (FTZs): Aluminum products must be admitted under “privileged foreign status” and are subject to duties upon withdrawal for consumption.
Updated List of Aluminum HTS subject to Section 232.
We will continue to monitor this situation and provide updates when available. Please contact us if you have any questions about this or any other trade matter.
